The information contained on this page has been provided by, and is the sole responsibility of, InfraRed Capital Partners Limited in its capacity as manufacturer of HICL’s shares for the purposes of the Consumer Duty.
What is the Consumer Duty?
The Consumer Duty is a set of rules introduced in 2023 that are designed to ensure that firms in the financial services industry provide a higher standard of care to retail consumers. If you are a retail customer, defined by the FCA as “all clients other than professional clients and eligible counterparties”, visit the FAQ page for key information.
Consumer Duty asks firms to deliver good customer outcomes in four key areas:
1) That products and services are well designed to meet the needs of customers in the target market
HICL is a FTSE250 listed investment company managed by InfraRed (the Investment Manager). HICL seeks to deliver sustainable income and capital growth from a diversified portfolio of investments in core infrastructure. More information about HICL’s structure and portfolio and how to invest can be found on the About Us, Portfolio and How to Invest in HICL pages.
For information on who an investment in HICL is suitable for which summarises the target market for the benefit of consumers, please see the relevant FAQ bellow. The full target market assessment can be found below in the Information for Distributors section. This should be read by Distributors.
2) That customers receive fair value
The price of HICL’s shares is determined by trading on the London Stock Exchange.
As Investment Manager to HICL, InfraRed aims to deliver a high quality investment proposition to investors, operating in a competitive industry with a focus on fees.
HICL maintains a competitive cost relative to similar products offered to investors. For the 2023 financial year, HICL’s ongoing charges ratio (OCR) was 1.09% (2022: 1.06%), calculated in accordance with the Association of Investment Companies’ guidance and defined as annualised ongoing charges (i.e. excluding acquisition costs and other non-recurring items) divided by the average published undiluted net asset value in the year.
The Company’s managers’ fees are tiered and reduce as the portfolio grows, meaning the Company’s costs are spread over a larger capital base.
HICL’s management fees are listed below:
- On the first £750m of portfolio value: 1.1%
- £750m-1.5bn: 1.0%
- £1.5bn-2.25bn: 0.9%
- £2.25-3.0bn: 0.8%
- £3.0bn+: 0.65%
- Plus £100k p.a.
In addition, HICL’s non-executive Board members receive fees commensurate with their experience and input which are approved by shareholders at each AGM. Neither the Manager nor the Board members receive performance or acquisition fees.
3) That communications enable consumers to understand products and services
We seek to make our communication through HICL’s website and in our communication with shareholders clear and easy to understand by those falling within our target market as described bellow.
4) That consumers are provided with appropriate support
We provide the firstname.lastname@example.org email address for consumers to contact the Investment Manager and the Company. We regularly monitor communication to this address and seek to respond promptly to queries. We also provide regular presentations to consumers through the Investor Meet Company platform, where it is possible to directly ask the Manager questions about the Company, as well as providing further relevant information on the HICL website including within the Investors section, and via the London Stock Exchange’s regulatory news service (also accessible via the Investors section on the web site).
You can follow HICL on Investor Meet Company here: https://www.investormeetcompany.com/hicl-infrastructure-plc/register-investor
Information for Distributors
Solely for the purposes of the product governance requirements contained within: (a) EU Directive 2014/65/EU on markets in financial instruments, as amended (Directive 2014/65/EU); (b) Articles 9 and 10 of Commission Delegated Directive (EU) 2017/593 supplementing Directive 2014/65/EU; (c) local implementing measures; and/or (d) (where applicable to UK investors or UK firms) the relevant provisions of the UK MiFID Laws (including the FCA’s Product Intervention and Governance Sourcebook (PROD)) (together the MiFID II Product Governance Requirements), and disclaiming all and any liability, whether arising in tort, contract or otherwise, which any ‘‘manufacturer’’ (for the purposes of the MiFID II Product Governance Requirements) may otherwise have with respect thereto, the New Shares have been subject to a product approval process, which has determined that: (i) such New Shares are compatible with an end target market of (a) retail investors who do not need a guaranteed income or capital protection, who (either alone or in conjunction with an appropriate financial or other adviser) are capable of evaluating the merits and risks of such an investment and who have sufficient resources to be able to bear any losses that may result therefrom, and (b) investors who meet the criteria of professional clients and eligible counterparties, each as defined in Directive 2014/65/EU; (ii) such New Shares are eligible for distribution through all distribution channels as are permitted by the MiFID II Product Governance Requirements; and (iii) the investors to whom such New Shares will be suitable include, but are not exclusively, those that satisfy the criteria in (i) and (ii) and who are seeking a financial product that promotes environmental and / or social characteristics, as defined under Article 8 of Regulation (EU) 2019/2088 (the Target Market Assessment).